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net operating loss carryback. If this information is
incorrect, please let me know.
Mr. Leonard, on behalf of petitioner, signed Form 872-A on May
28, 2002, and Mr. Kaufman signed it on behalf of respondent on
May 29, 2002. The Form 872-A signed by the parties had not been
altered by any insertions, additions, or deletions. The legal
effect of the Form 872-A signed by the parties is in dispute.
On June 4, 2002, respondent issued a notice of deficiency in
the Becker case determining that Mr. Becker must recognize
$5,307,600 of ordinary income during the taxable year 1996.
On July 8, 2002, Mr. Leonard again wrote Mr. Kaufman and
stated:
As we have discussed, my client, Becker Holding Corporation,
hereby accepts the proposal which you outlined in your April
18, 2002 letter. As I understand your proposal you will:
(1) allow 80% of the remaining $5,307,000.00, to wit
$4,246,000.00 as a deduction in the 1996 fiscal year.
This would increase the net operating loss for 1996,
which would be carried back to the 1993 fiscal year.
(2) allow a fuel tax credit for 1993 which was being
disputed as a double deduction, but which in fact was
not, in the amount of $87,467.00.
(3) make no changes to tax years 1991 and 1992.
As we had also discussed, there remain issues outstanding
for the above stated tax periods, as well as tax period
ending 09/1997, with which we would request your assistance,
but which are not contingencies to the acceptance of your
proposal.
* * * * * * *
As you can see, my clients would like to resolve any
outstanding issues for tax years 09/1991 through 09/1997
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